schädlich

English translation: harmful/tainted

Advertisement

Login or register (free and only takes a few minutes) to participate in this question.

You will also have access to many other tools and opportunities designed for those who have language-related jobs (or are passionate about them). Participation is free and the site has a strict confidentiality policy.

16:51 Oct 20, 2006

German to English translations [PRO]Law/Patents - Finance (general)

German term or phrase:schädlich

if an action is said to be 'schädlich' in the context of a particular law, does this mean that it is 'schädlich' for the person doing it ie has harmful consequences for him/her, or does it mean that it is 'schädlich' to the law ie in violation of it/in conflict with it.

Explanation:Especially in tax contexts, the term of art is "harmful", or that a particular course of action is "tainted" (resulting in "tainting"). And yes, this means that it has adverse tax consequences for the fiscal entity (Steuersubjekt) in question.

I imagine the KSt context you're referring to here has to do with the tax treatment of intercompany loans with associated share transfers, upstream/downstream mergers, or plain-vanilla thin capitalisation, under what are known as the "anti-debt pushdown rules", or the "back-to-back financing rules".

Thanks Robin. I had noted that both Deloitte's and KPMG use 'harmful' but wasn't sure whether this was Denglisch. Context was transferability of loss carryforwards in mergers, btw.4 KudoZ points were awarded for this answer

Explanation:Especially in tax contexts, the term of art is "harmful", or that a particular course of action is "tainted" (resulting in "tainting"). And yes, this means that it has adverse tax consequences for the fiscal entity (Steuersubjekt) in question.

I imagine the KSt context you're referring to here has to do with the tax treatment of intercompany loans with associated share transfers, upstream/downstream mergers, or plain-vanilla thin capitalisation, under what are known as the "anti-debt pushdown rules", or the "back-to-back financing rules".